Modern Slavery Policy Statement

This statement has been published in accordance with Section 54 of the UK Modern Slavery Act (2015). It sets out the steps taken by Maylim Limited during the financial year ending 5th April 2022 to prevent slavery, forced labour and human trafficking from taking place in any part of the business’ operations, or that of its supply chain. From here on in, Maylim Limited will be referred to as ‘Maylim’ or ‘the Company’.

Introduction

Maylim is committed to conducting business honestly and with integrity; both in terms of the Company’s operations and respect and value for the workforce and partnerships. Maylim strives to treat all people with dignity and has developed and adopted a pro-active approach in deterring, identifying and tackling hidden labour exploitation. Maylim does not tolerate any kind of forced labour, child labour or exploitation. The Company’s intention is to encourage awareness of the issues around modern slavery and to ensure early identification of issues or concerns of human trafficking and forced labour, in line with the guidance set out in the Modern Slavery Act (2015).

Organisation Structure and Supply Chain

Maylim works across both public and private sectors delivering high-quality external works and landscaping schemes, as well as highway and civil engineering projects. The Company carries out work as either principal contractor, working directly for a client, or as a first-tier contractor working under a principal contractor. Maylim employs a number of its workforce directly but also uses regular contract labour and will sub-contract work packages to other companies where applicable. Sub- contractors supply their own labour to work for Maylim.

Maylim has a diverse workforce and employs people from outside of the UK, both directly and through sub-contractors. Migrant workers are often more vulnerable to human trafficking and associated forms of exploitation. It is within Maylim’s company policy to check the identity and right to work for all directly employed staff. It is also stated within this policy that all sub-contractors and employment agencies are to conduct their own checks in accordance with UK visa and immigration enforcement guidelines.

In addition, Maylim’s supply chain also consists of suppliers of goods, services and materials. The majority of the materials used in Maylim’s operations are procured internally. There is a preference  to source materials from the UK however, this is not always possible due to commercial availability. For this reason Maylim’s supply chain incorporates suppliers based in some countries where there is a greater risk of modern slavery issues. In order to mitigate this risk, Maylim only uses an approved list of suppliers with an identifiable and distinct legitimate business entry.

Modern Slavery in Collaboration With Other Policies

This policy statement operates in conjunction with Maylim’s policies on Code of Conduct, Equality, Diversity and Inclusion Policy, Dignity at work, Anti-bribery and fraud prevention, whistleblowing and Ethical policy. These policies are designed to ensure that Maylim is acting ethically and with integrity in the way it operates as a business. Maylim’s policies frame the Company’s standards and ethics, helping to ensure that unlawful discrimination or business practices are avoided. To ensure their effectiveness, Maylim’s policies are accessible to all employees on the Company server and via PeopleHR.

Due Diligence Processes and Effectiveness 

In the last financial year, in order to minimise the risk of modern slavery in the supply chain, Maylim has:

  • Continued to check the identity and Right to Work of all directly employed staff in accordance with UK visa and immigration enforcement guidelines;
  • Requested for all suppliers and sub-contractors to provide details of their own policies and procedures in regard to the measures they are taking to ensure their workforce is eligible to work in the UK;
  • Introduced Fareclock software across all business operations. Registration on Fareclock is a prerequisite for all staff before commencing work for Maylim (this includes agency labour and sub-contractors). Proof of identity and Right to Work checks form part of this process. Fareclock allows the Company to keep a secure record of all labour across Maylim sites using biometric recognition;
  • Registered as a member of the Supplier Ethical Data Exchange (SEDEX) platform. SEDEX is dedicated to driving improvements in responsible business practices and increasing transparency in supply chains. SEDEX allows companies to map their supply chain and assess risks regarding labour standards, health and safety, environment and business ethics;
  • Continued to protect whistleblowers making disclosures under the Company’s Whistleblowing Policy;
  • Remained a registered member of the Stronger Together initiative to reduce modern slavery. Maylim has continued to utilise guidance, tools and resources to ensure the company is kept up to date with best practice and legislation for how to manage the risk of modern slavery within business, and;
  • Continued to share knowledge and improve understanding of modern slavery issues amongst the workforce and across the supply chain. This is achieved via the company induction, toolbox talks, posters and leaflets on site, and employee awareness training.

TrainingCommitmentsfortheComingYear

  • Maylim will continue to develop its commitment to tackling forced labour and human trafficking by developing a tiered training system to further raise awareness and educate the workforce and  supply chain over the risks and prevention of modern slavery. Maylim will ensure that improving ethical labour standards and tackling modern slavery is a fixed term agenda item; not only for discussion during meetings with labour providers but also internally as part of the Company’s ongoing strategic review.
  • Maylim will assign appropriate managers to attend the formal training ‘Tackling Modern Slavery in the Construction Sector’. These managers are also responsible for developing and operating company procedures relevant to this issue.
  • All existing Maylim employees will undertake awareness training in recognising, preventing and reporting forced labour, labour trafficking and other hidden third-party labour exploitation.
  • Maylim’s induction training for new workers will include the provision of training on how to recognise and report forced labour, labour trafficking and other hidden third party labour exploitation. Using Stronger Together’s resources, Maylim will raise awareness and provide the appropriate guidance on how to recognise these signs.
  • Maylim will only work with contractors and suppliers (including labour providers and recruiters) that have taken part in the Company’s pre-qualification questionnaire process and are approved by Maylim as meeting the same ethical business standards of the Company.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act (2015) and constitutes Maylim’s modern slavery and human trafficking statement for the financial year ending 2022.

Signed on behalf of Maylim Limited

Signed:

Thomas O’Mahony

Date: 15.06.2023